System and method for processing formatted text documents in a database

ABSTRACT

A system and method for automatically determining a plurality of pieces of different information about a textual document from the text of the textual document are provided in which one or more particular characteristics of the text of the textual document are identified to generate a file containing the text of the textual document with the particular characteristics marked up within the text. In addition, any negative treatment of other textual documents from the text of the textual document is determined to generate negative treatment information, a data record is produced indicating a depth of treatment for each other textual documents cited in the text of the textual document, the source of a quotation in the text of the textual document is verified to generate verified quotation information, any subject matter text that is applicable to the text of the textual document is determined to generate subject matter headings associated with the text of the textual document, and a data record is generated containing the identified characteristics of the textual document, the negative treatment of other textual documents cited in the textual document, the depth of treatment of other textual documents cited in the textual document, the verified quotation information, and the subject matter text associated with the textual document so that all of the information is accessible.

CLAIM OF PRIORITY

This application is a continuation of U.S. patent application Ser. No.09/746,557, filed on Dec. 22, 2000, which is a continuation of U.S.patent application Ser. No. 09/120,170, filed on Jul. 21, 1998, all ofwhich are incorporated by reference in their entirety.

BACKGROUND OF THE INVENTION

This invention relates generally to a system and method for processing aplurality of textual documents and in particular to a system and methodfor identifying characteristics within the textual documents and forextracting relationships between the textual documents based on theidentified characteristics.

The explosion in the number of textual documents being generated hasmade it increasingly important to generate an electronic version of thedocuments to enable automated processing to extract data, to determineinformation about the textual documents, and to identify relationshipswith other textual documents in a database. This is especially true withvery large databases which may contain hundreds of thousands of textualdocuments, such as a database containing legal cases and other legalmaterial.

A legal database may contain a large number of legal cases. A legal casein this document refers to an individual written decision issued in thecourse of a litigation. These decisions usually contain citations to andquotations from other documents, including other legal cases toestablish past practice and justify the result (establish precedence) ofthe decision. Citations are written in distinctive styles which includesspecial abbreviations and punctuation which facilitate theiridentification. Also, quotations are usually set off in quotation mark.It is useful to identify these citations and quotations.

In some circumstances, the citations and quotations in a legal case maybe identified by automatically parsing through the text of a legal caseto identify candidates based upon punctuation and other characteristics.However, the punctuation which sets off a quotation may be used forother purposes, and the abbreviations and formats which characterize acitation are not necessarily unique. To ensure accurate identification,a citation or quotation must be verified. A citation has a predefinedformat. For example, a written decision of a California Court of Appealscase in 1993 in a lawsuit between Ms. Pleasant and Mr. Celli may have acitation such as, Pleasant v. Celli, 18 Cal. App. 4th 841, 22 Cal. Rptr.2d 663 (1993). The first portion of the citation indicates the twoparties last names and their positions in the case. For example, Ms.Pleasant is the first name listed. Since this is an appellate case, sheis the appellant and Mr. Celli is the appellee. The next portion of thecitation (i.e., 18 Cal. App. 4th 841 for example) indicates where a copyof the written decision may be located. The first number indicates thevolume number of the case reporter in which the decision is located andthe text portion (i.e., Cal. App 4th) indicates the name of the reporterand the edition of the reporter. The number following the reporter nameindicates the starting page number of the decision. Thus, both the textof the citations and quotations in a written reported decision textualdocument have well defined format which may be automatically identified.

Once the citations and quotations in a legal case are identified and anyrelationships between these citations and quotations and any prior legalcases are determined, this information may be used for a variety ofpurposes. For example, this information may be used for both legal caseverification purposes and legal case collocation purposes. Verificationis a process whose end result is a determination that the legal casecurrently being reviewed is still good law (i.e., it has not beenoverruled or limited by some later case due to different reasoning). Acase that is not good law may not be persuasive since the reasoning ofthe case is no longer valid. Thus, the process of verification ensuresthat the case being used to support an argument is still good law andthe reasoning of that case is still valid. Collocation, on the otherhand, is a process whose end result may be a list of other legal cases,legal materials or textual documents which cover similar issues to thecase currently being reviewed, or a list of cases covering a particularsubject matter, such as intellectual property. For example, a user ofthe legal database may have located a case which is of interest to himand he would then like to identify other cases that are related to thecase of interest based on the subject matter. Thus, it is desirable fora user of a legal database to be able to perform both verification andcollocation using a single integrated system.

Prior to electronic databases, legal cases were published in severaldifferent formats each of which have some advantages and disadvantages.A register publication gathers information at the source of the new lawand presents the new law in roughly chronological order. An example ofthis type of publication is a reporter volume that contains the newlegal cases for a particular court in chronological order. Theseregister publications may be rapidly published and provide a goodstatement of the new law, but these register publications cannot providecollocation (i.e., it cannot provide a researcher with information aboutother cases which may be related to the subject matter of the instantcase). It is also difficult to verify a legal case with a registerpublication. Another type of legal publication is a code publicationwhich attempts to gather together the law that applies to a particularsubject matter so that a researcher may determine the current state ofthe law from a single source. A code publication may permit a case to beverified since outdated law is removed as a code publication is updated.An example of a code publication is an annotated statutory codepublication which gathers information from statutes and legal casesabout a particular subject matter. Legal case are not published in acode format. These code publications may provide a researcher with theability to collocate legal cases and verify a legal case, but theinformation in these code publications, due to the amount of timerequired to compile these code publications, only describe the state ofthe law sometime in the recent past. Therefore, for rapidly changingareas of the law, a code publication may not be accurate and thereforecannot provide either the verification or collocation needs to theresearcher.

Numerous efforts have been made to codify case law, but case law tendsto resist codification for several reasons. First, there is atremendously large number of legal cases so it is often very difficultand time consuming to attempt to classify the legal cases by subjectmatter. In addition, legal cases have a complex hierarchy of authorityand control (i.e., whether a case from a particular court controls orinfluences the outcome of another court, which leads to differencesbetween various courts within various regions of the United States. Itis also very difficult to determine the effects that a newly-decidedlegal case may have on the current state of the law. The attempts tocodify the case law have included treatises (which cover the currentstate of the law for a particular subject matter) or restatements of thelaw in particular subject areas.

In order to adequately perform legal research, legal researchers need tobe able to determine the current state of the case law, and then accessthe case law in its register form. Any access to the case law itself orfree-text access cannot easily provide a current state of the law. Thus,a researcher may use an index to the case law to find the case law.These indexes include a controlled vocabulary, manually createdintellectual index to case law which requires extraordinary amounts ofmanpower to implement. Instead of these options, a citation index (alsoknown as a case law citator) may be used.

There are several conventional case law citators. One citator providesboth the required verification and collocation functions, but hasseveral disadvantages. In particular, this citator produces citationchains for a particular legal case which list how the legal case wastreated by later legal case, such as indicating that the particular,legal case was overruled or followed. This citator is not current sinceit typically waited for a legal case to be in the general case law priorto generating the case law citator information. This conventional systemdid an adequate job of verification, but did not really provide anadequate collocation function. In particular, it is tedious to locateother case law which relates to a particular case by following thecitation strings, retrieving the reporter with a legal case, and thenmanually reviewing the legal case.

Therefore, it is desirable to provide a system and method whichseamlessly integrates general subject matter access to case law withcitation information which provides a researcher with the desiredverification function as well as the collocation function. Thus, theresearcher may use a single integrated system which provides theresearcher will all of the information that the researcher needs in asingle location. The invention provides such a system, as describedbelow.

SUMMARY OF THE INVENTION

The invention provides a system which processes a textual document, suchas a legal case, automatically generates information about the textualdocument, and automatically establishes relationships between thetextual document and other textual documents in a database based on thegenerated information. The system then permits a user of the system toselect a textual document and view any other textual documents whichhave a particular relationship to the selected textual document based oncitations in the selected text document.

This invention provides some automated processes which make it possibleto create an index both more quickly and more economically. In addition,the system provides a user with a richer characterization of eachcitation because it provides information about the citation in agraphical manner.

In one aspect, the invention provides a legal database system that usesan automatic text processing system to permit a researcher to verify alegal case as well as to collocate other legal cases. The automatic textprocessing system processes each legal case to generate informationabout the legal case, and then establishes relationships between thelegal case and other legal cases based on certain criteria. To providethese functions in a efficient, cost effective manner, the automatictext processing system may identify and verify quotations in the writtenreported decision of the legal case, generate information about“negative treatment” of the legal case by other legal cases (e.g., thereasoning of a written opinion of a legal case may be disagreed with,overruled or distinguished by the written decisions of other legalcases), generate “depth of treatment” information (e.g., thesignificance of a citation in a written decision of the legal case basedon, for example, how much effort and words were spent discussing thecited case), and generate a subject matter classification for eachcitation in the legal case. The system reduces the time necessary toprocess a legal case and reduces the cost to provide case law citationinformation yet maintains the same accuracy as a conventional system.The invention also parses a textual document, identifies any quotationsin the textual document and verifies the source of the quotation. Theinvention also determines a subject matter classifications for eachcitation identified in a legal case.

In accordance with the invention, a system for automatically determininga plurality of pieces of different information about a textual documentfrom the text of the textual document is provided. The system maygenerate a data record containing the identified characteristics of thetextual document, the negative treatment of other textual documentscited in the textual document, the depth of treatment of there textualdocuments cited in the textual document, the verified quotationinformation, and the belief scores of the top-ranked headnotes so thatall of the information is accessible. To generate the data record, oneor more particular characteristics of the text of the textual documentare identified to generate a file containing the text of the textualdocument with the particular characteristics marked up within the text.Any likely negative treatment of other textual documents from the textof the textual document may be identified to generate negative treatmentinformation, a data record is produced indicating a depth of treatmentfor each other textual documents cited in the text of the textualdocument, the source of a quotation in the text of the textual documentis verified to generate verified quotation information, and any subjectmatter text that is applicable to the text of the textual document isdetermined to generate subject matter headings (e.g., headnotes)associated with the citations in the text of the textual document.

In another aspect, the invention provides a method for processing atextual document to identify quotations within the textual document inwhich the text of the textual document is parsed into one or moreparagraphs and one or more symbols are identified in each paragraph. Thesymbols, such as quotation marks, indicate the presence of a quotationin the sentence, and quotations within the text of the textual documentare determined based on the identified tokens. In addition, a source ofthe quotation is verified by matching the text of the quotation with thetext of the actual quotation within the textual document, and a verifiedquotation data record is generated.

BRIEF DESCRIPTION OF THE DRAWINGS

FIG. 1 is a block diagram of a computer system which may be used toautomatically generate case law citation data in a legal text processingsystem in accordance with the invention;

FIGS. 2A-2D are screen shots illustrating examples of the user interfacedisplayed to a user of the case law citation system in accordance withthe invention;

FIG. 3 is a diagram illustrating the flow of data in a case law citationsystem in accordance with the invention;

FIG. 4 is a diagram illustrating more details of the flow of data in thecase law citation system of FIG. 3.

FIG. 5 is a diagram illustrating a system for quotation identificationin accordance with the invention that may be part of the case lawcitation system;

FIG. 6 is a flowchart illustrating a method for quotation identificationand verification process in accordance with the invention;

FIG. 7 is a flowchart illustrating a method for quotation verificationin accordance with the invention;

FIG. 8 is a diagram illustrating a negative history determining processin accordance with the invention;

FIG. 9 is a flowchart illustrating a method for determining the depth oftreatment of a legal case in accordance with the invention; and

FIG. 10 is a diagram illustrating a method for assigning subject matterclassifications in accordance with the invention.

DETAILED DESCRIPTION OF A PREFERRED EMBODIMENT

The invention is particularly applicable to a computer-implemented legaltext processing system and method for semi-automatically identifyingcharacteristics, such as citations and quotations, within a legaldocument and identifying relationships between the legal document andother legal documents stored in-the database. The legal document may bea legal case, a statute, a law review article, an ALR article or a legaltreatise. It is in the context of a legal case that the invention willbe described. It will be appreciated, however, that the system andmethod in accordance with the invention has greater utility and may beused for different legal documents.

Before describing the preferred embodiment of the invention, a briefdescription of the terminology that will be used to describe theinvention will be provided. Any reported decision of a legal case ispresumed to be an authoritative statement of the law when it is written.Then, later events may affect the authoritativeness of this legal case'sdecision. These later events may include later proceedings or writtendecisions during the same litigation (e.g., direct history), a decisionof a later legal case from a different litigation which resolves thesame issues in a different way or using different reasoning andoverrules the earlier case, or a decision of a later legal case from adifferent litigation which resolves the same issue differently, but doesnot explicitly overrule the case. The direct history of a legal case mayinclude a record of the connections between the legal cases that arepart of the same litigation. The direct history may be of varyingdegrees of relevance and may include positive history (i.e., maintainingor supporting the authority of the legal case) or negative history (forexample, the legal case may no longer have the authority it once had)).The indirect history of a case is a record of the connections betweenlegal case and other legal cases which are not part of the samelitigation. The indirect history of a legal case may also be positive ornegative. The significance of a particular case may often be indicatedby the amount of discussion (i.e., the amount of text) that a later caseuses in discussing a decision of another legal case while following,overruling or explaining the case. This is referred to as the depth oftreatment of the case, as described below. Now, a preferred embodimentof the invention will be described.

FIG. 1 is a block diagram of a computer system 30 in which the inventionmay be embodied. The system may semi-automatically identifycharacteristics, such as citations and quotations within a legal casedocument, and then generate information about the legal case in thecontext of other legal cases. The computer system may include a computer32, a server 34 and a plurality of client computers 36. The computer 32may further include a central processing unit (CPU) 38, a memory 40 andone or more processes 42, which may be software applications that arestored in the memory 40. The CPU controls the operation of the computerand executes the software applications stored in the memory. Inoperation, a plurality of pieces of electronic data corresponding to thetext of the published decisions for the legal cases are fed into thecomputer and temporarily stored in the memory 40. In the followingdiscussion, the written opinion of the legal case is referred to as thelegal case. Each piece of electronic data (i.e., each written opinion ofa legal case) may be automatically processed by the CPU, using theprocesses contained in the software applications contained in thememory, to generate information about the legal case, as describedbelow. For example, the CPU may parse the text of the legal case toidentify candidate (i.e., unverified) citations to other legal cases andmark these citations for later processing, may identify candidate (i.e.,unverified) quotations in the text of the legal case and mark the textaccordingly, may verify the source of a quotation in the text of thelegal case, may determine a depth of treatment of a cited legal case(i.e., the significance of the cited legal case based on somepredetermined criteria), may determine the negative treatment of thelegal case, and may assign subject matter text, such as headnotes, inaccordance with a predetermined classification system to citations inthe legal case. Each of these processes may be performed by a softwareapplication in the memory 40, which is executed by the CPU 38. Thedetails of each of these processes will be described below.

Once the processing has been completed by the processes 42, the computer32 outputs a data record 44 for the particular legal case which containsinformation about the history of the legal case, information about thedepth of treatment of citations in the legal case, information aboutquotations within the legal case, and information about the subjectmatter text (i.e., headnotes) assigned to each citation in the legalcase. The data record generated by the computer 32 for each legal casemay be stored in a database 33 in a server 34. Then, when a user of oneof the plurality of client computers 36 requests information about alegal case, the server 34 generates a user interface containing avariety information about the requested legal case based on the datarecords in the database 33, and presents the user reviewing the legalcase with a variety of information about the legal case. An example ofthe user interface provided to the user of each client computer isdescribed below with reference to FIGS. 2A-2D. In this manner, a user ofthe client computer may request data about a particular case, and thesystem in accordance with the invention provides that data to the user.

As the electronic data for the text of each written opinion for a newlegal case is received by the computer 32, the legal case is processedas described above and the results of the processing is stored as a datarecord 44 in the database 33 of the in the server 34. The users of theclient computers may then retrieve data about a particular legal casefrom the server 34. Thus, while the server 34 is providing data about alegal case to the one or more users of the client computers, thecomputer 32 may be simultaneously processing additional new legal casesand adding the information for that new legal case into the database 33in the server 34. Now, an example of a preferred user interface andinformation provided to the user of a client computer will be describedin more detail.

FIGS. 2A-2D are screen shots illustrating examples of a preferred userinterface and the information provided to the user of a client computerin accordance with the invention. FIG. 2A shows a computer screen 50 ona client computer displaying a legal case being reviewed by the user ofthe particular client computer in which the user interface has a Windowsformat, a toolbar, pull down menus, etc. In this example, the display isof the text of a legal case called Pleasant v. Celli which was decidedby a California Court of Appeals. As described above, any citation for alegal case has a well-defined format which facilitate the identificationof these citations within the text of the written opinion of the legalcase. In order to access more information about the displayed legalcase, the user of the client computer may select the citation service,which may be referred to as KeyCite™, from the Services menu 51 byclicking on a “KC” button 52 or click on a symbol 54. KeyCite™ is atrademark of a citator of the assignee of the present invention. Thesymbol may be a colored symbol, e.g., a flag, which gives a quick statusof the legal case. A red colored flag may warn that the legal case beingreviewed may not be good law for at least some portion of the legalcase, a yellow colored flag may indicate that the legal case has somenegative history, as described below, or another colored symbol, such asa blue H, may indicate that the legal case has some history which is notnegative. The invention, however is not limited to any particular typesof symbols or colors. Once the user of the client computer has selectedthe citator system in some manner, the screen shown in FIG. 2B may bedisplayed.

FIG. 2B is a screen shot showing an example of a computer screen 50which the invention may employ having a control interface portion 58,and a display portion 60. The control interface portion of the displaypermits the user to customize the information being displayed. Forexample, if a first radio button 62 is selected, then the full historyof the legal case, including direct history which is negative orpositive, negative indirect history, and any related references may beshown. If a second radio button 64 is selected then only the negativedirect and indirect history may be shown. If a third radio button 66 isselected, then only the direct history of the legal case may bedisplayed so that any minor direct history (including references),remote direct history (such as appeals after remand) and mildly negativeindirect history are not displayed. The control portion 58 of thedisplay also may indicate the number of cases which are considered to bethe history of the legal case. The control portion 58 may also include afourth radio button 68 and an indication of the number of citations tothe legal case being displayed. When the fourth radio button isselected, a list of other documents is displayed.

In the example shown in FIG. 2B, the full history of the Pleasant v.Celli case is indicated. As shown, the various types of history, such asthe direct history and the negative indirect history are displayed inthe display portion 60 and are separated from one another by headings.For each piece of history, a short description of the history or tag,such as “opinion vacated by”, “disapproved of by”, or “disagreed withby” may indicate the relationship between the cases listed and the basecase. In this example, an earlier decision of the same court was vacatedby the Pleasant case. Now, the citations to the legal case will bedescribed with reference to FIG. 2C.

FIG. 2C is an example of a screen shot showing the computer screen 50having the control interface portion 58, and the display portion 60.This screen displays the legal cases which have cited the legal casecurrently being reviewed (i.e., Pleasant v. Celli in the example). Inthis screen shot, the fourth radio button 68 is selected. Thus, thecontrol portion may also have a button 70 which permits the user of thesystem to limit the types of citations displayed, as described belowwith reference to FIG. 2D. The display portion 60 may also display aquotation mark symbol 72 and a depth of treatment symbol 74, which areassociated with the citations for the legal case, etc. which cite to thelegal case of interest. The quotation symbol 72 indicates that the citedlegal case directly quotes from the case of interest (i.e., in theexample Lubner v. City of Los Angeles contains a quotation from Pleasantv. Celli). A method for identifying quotations and verifying the sourceof the quotations in accordance with the invention will be describedbelow. The depth of treatment symbol 74, which may be, for example, oneor more stars, where the number of stars indicate the degree to whichthe legal case's written opinion is treated, e.g., the amount of text inthe cited case opinion which is devoted to the case of interest. Thedetails of the depth of treatment assignment process will be describedbelow in more detail. Now, a screen which permits a user to the limitthe citations displayed in the display portion will be described withreference to FIG. 2D.

FIG. 2D is an example of a screen shot showing the computer screen 50with the control portion 58 and the display portion 60. In this screenshot, it is assumed the user of the system has selected the limitcitation button 70 shown in FIG. 2C. As shown, the user of the systemmay restrict the citations displayed based on headnotes or topics andthe system will evaluate all of the citations against the selectedheadnotes or topics so that only the legal cases containing the selectedheadnotes or topics are displayed in the screen shot shown in FIG. 2C. Aheadnote may be a few sentences/paragraph which are located at thebeginning of a legal case and indicate a summary of the law of aparticular portion of the legal case. The user interface of the systempermits a researcher to quickly and efficiently perform verification andcollocation functions on a legal case. The details of the system forgenerating information about the legal case and providing theverification and collocation functions in accordance with the inventionwill now be described.

FIG. 3 is a diagram illustrating a method 100 in accordance with theinvention, which may be implemented on the computer system of FIG. 1,for processing a legal case to generate information about the legal casewhich may be used for verification and collocation functions. As an aidin understanding the processes, the movement of a single legal case willbe described. It should be understood, however, that a plurality oflegal cases may be processed at the same time since each legal case maybe at a different point in the process. An electronic version of thetext of a legal case 102, referred to herein as “WL LOAD”, is fed into acitation identification process 104 (ACITE) that identifies candidatecitations to other legal cases and other legal material within the textof the legal case, and marks up the text, i.e., adds a characteristicmark-up symbol to the text, so that the citations may be easilyidentified at a later time. An example of a mark up symbol may be thatthe symbol combination “% v” placed at the beginning and at the end ofthe citation. This identifies the citation for later processing.

Briefly, the citation identification process identifies candidatecitations by identifying certain patterns of text in the legal documentand compares these patterns to a predetermined set of referencepatterns. In particular, digits may be first identified in the text.Next, the text is scanned for abbreviations proximate to the digitswhich correspond to known reporter abbreviations, such as “Cal.” or “P.”Once a piece of text having the particular formatting and punctuation ofa candidate citation is identified, a case control database 124 isqueried to determine if the identified candidate citation corresponds toa valid citation in the case control database. If the identifiedcandidate citation matches a citation in the case control database, asecond processing pass is performed. If no match is located, theidentified candidate citation may be flagged for later manual review. Asdescribed above, each citation has a predetermined format. The formatmay be <case name>, <volume number> <abbreviation of reporter name><series number (if more than one)> <page number in volume>. For example,in “18 Cal. App. 4th 841”. “Cal. App. 4th” refers to the “CaliforniaAppellate” reporter, 4th series; “18” refers to volume 18; and “841”refers to page 841, the page of volume 18 of Cal. App. 4th where thecase decision begins.

As example of a citation to a legal case is Pleasant v. Celli, 18 Cal.App. 4th 841, 22 Cal. Rptr 2d 663 (1993) in which the first nameportion, i.e., Pleasant v. Celli, identifies the parties of the legalcase; the second reporter portions, i.e., 18 Cal App. 4th 841 and 22Cal. Rptr 2d 663, identify the reporters which themselves have aparticular characteristic format as described above.

Once text corresponding to a reporter name is located, the text adjacentthe reporter name is analyzed to identify the volume, series and pagenumber of the citation as well as the year of the published opinion.Once this information is found, the candidate citation is identified andmarked up, as described above, to identify it as a citation. Thecitation identification process may use a two pass process in whichfirst, full format citations, such as Pleasant v. Celli, 18 Cal. App.4th 841, 22 Cal. Rptr 2d 663 (1993), are identified, matched to the casecontrol database, and placed within a table. In a second pass throughthe legal case, short form citations, such as Pleasant, may beidentified based on the text of the full citations that are contained inthe table. It should be noted that these short form citations cannot beidentified automatically without first identifying each full citation.For doubtful short form citations which don't match the table, atentative identification may be made.

The citation identification process 104 in FIG. 3 outputs a file 106containing the text of the legal case with any citations marked up. Thefile 106 may then be fed into a quote identification process 108(IQUOTE) in which the text of the legal case is parsed quotations in thetext of the legal case are identified and marked up, and a possiblesource of the quotation is also identified. At this point, the marked upquotations have not been verified. They are merely candidate quotationswhich must be further processed to be verified. The details of the quoteidentification process will be described below with reference to FIGS.4-6. The quote identification process may output a file 110 thatcontains the text of the legal case in which both the citations and thequotations are marked up. At this point, the text of the legal case withthe citations and quotations mark-ups may be stored in a database forlater use and may also be fed into several processes. These processesmay include a quote verification process 112, a depth treatment process114, and a negative treatment process 116. As shown, these processes mayexecute in parallel on the same file since each process generatesinformation about the legal case which is separate and independent fromthat generated by the other processes. Each of their processes will bedescribed in more detail below with reference to FIG. 7, FIG. 9, andFIG. 8, respectively.

In general, the quote verification process 112 verifies that thecandidate quotations identified by the quote identification process 108are in fact from the source (i.e., the citing case) by comparing thecandidate quotation in the cited case to the quotation in the citingcase. The process then generates a data record 118 containinginformation about the verified quotation. The depth treatment process114 uses information generated by the system, including the verifiedquotations to generate depth treatment information, such as the numberof occurrences of a citation and the characteristics of the citationbased on its position (e.g., whether it is free standing, at the head ofa string or in the interior of a string). The process then generates adata record 120 containing information about the depth of treatmentinformation that is applied to each citation in the case of interest.The negative treatment process 116 generates information about anynegative treatment the case of interest has received by any of theciting cases and, in step 122, a database 124 containing informationabout each legal case being processed is updated manually to reflect thenegative treatment. The data records 118, 120 from the quotationverification and depth treatment processes, respectively, may becombined together by a grouper process 126 along with a headnoteassignment data record 128 (HNRESULT), as described below, to generate asingle data record containing the depth treatment information, thequotation information, and the headnote assignment information, aboutthe legal case being processed. This single data record may then be usedto generate the information displayed on a computer screen to the useras shown in FIGS. 2A-2D.

The data record 118 containing the information about the verifiedquotations in the legal case also may be fed into a citation lociidentification process 130 which attempts to identify the supportingtext surrounding quotations and citations in the legal case to generatea citation loci data record 132. The citation loci data record may thenbe input into a subject matter assignment and thresholding process 134which matches the words and phrases in the quotations to one or moreheadnotes or topics and then determines, based on a threshold value,which headnotes are selected, as described below with reference to FIG.10. The subject matter assignment and thresholding process 134 outputsthe data record 128 (HNRESULT) containing the selected subject mattertext, such as headnotes, which is fed into the grouper 126, as describedabove. Thus, the system in accordance with the invention automaticallygenerates information about a legal case and then provides thatinformation, using a graphical user interface, to a person using thesystem when requested. The user may quickly and efficiently locatevarious information, such as citation information, depth of treatmentinformation, negative treatment information and subject matter text,such as a headnote, about the legal case from a single source. Moredetails about the system will now be described with reference to FIG. 4.

FIG. 4 is a diagram illustrating more details of the quoteidentification process 108, the quote verification process 112, thedepth treatment process 114, the negative treatment process 116, thecitation loci identification process 130 and the subject matterassignment and thresholding process 134 of FIG. 3. As shown, the outputsfrom each of these processes are fed into a system information database33, as described above.

The quote identification process 108 uses the file containing the textof the legal case with marked up citations to identify and mark-upquotations as described above. The text of the legal case containsunverified quotations while the file 144 containing the verifiedquotations is stored in the database 33. The output of the quoteidentification process is a plurality of data records in which each datarecord has an identified quotation and a possible source of thequotation. The output of the quote identification process may becombined with the file containing the text of the legal case and themarked up citations to produce a file with marked up citations andquotations 110 which is used as an input to the depth of treatmentprocess 114, the negative treatment process 116, the loci identificationprocess 130 and the subject matter assignment and thresholding process134. During the quote identification process 108, as described below inmore detail with reference to FIGS. 5 and 6, several processes areperformed. First, candidate quotations in the text file are identifiedby scanning the text to identify symbols, e.g., quotation marks, whichindicate the beginning or end of a quotation. Next, the beginning andend of the identified quotations are marked up with a quote identifiersymbol, such as “% q”. Finally, a possible source of the quotations,such as the legal case or other legal material from which the quotationsoriginate is tentatively identified. The source of the quotation is thenverified during the quote verification process 112 as described below.The output of the quote identification process 108 may include a Qdatafile 140 which contains information about each quotation that is laterverified against the probable source of the quotations and a Qtxt file142 which contains the actual text of the quotations.

The Qdata and Qtxt files 140, 142 are then fed into the quoteverification process 112 which uses an electronic database of legalcases, already available, to find and verify the possible source of eachquotation found by the quotation identification process. For eachquotation, the possible source of the quotation is retrieved. Next, thequotation identified by the quotation identification process is matchedagainst the text of the possible source to locate text in the sourcecorresponding to the quotation. This verifies the source as the originof the quotation. For each quotation with a verified source, a datarecord 144 containing the verified quotations for a legal case is storedin the database 33. Then, when a legal case containing verifiedquotations is displayed as a citation to a legal case, the citation willcontain a quotation symbol, as described above, indicating that thelegal case has a verified quotation. The depth treatment process willnow be described.

The depth treatment process 114 may receive the file 110 containing thelegal case text with the marked up citations and quotations and, in step146, the depth treatment process performs several processes in order todetermine the significance of the citation based on a set ofpredetermined criteria that are related in some ways to significance.These criteria may be the number of times that the citation appeared inthe legal case, the type of the citation, and the association of averified quotation with the citation. First, the depth treatment processreads through the file 110 and identifies citations which have beenmarked up previously by the citation identification process. For eachidentified citation, the type of the citation is determined to be eitheran ordinary citation, a middle of a string citation, or the head of astring citation. An ordinary citation is a typical citation whichusually appears within a legal case and that does not have othercitations adjacent to it. A middle of a string (interior) citation is acitation that appears in the middle or at the end of a string citationin which a series of legal documents are cited together in a sentence orparagraph. An interior citation is usually perceived by users ascontributing less to the depth with which the cited case is discussed.The head of string citation is a citation that appears at the beginningof a string citation and is perceived by users as contributing more tothe depth since it is conventional to place the most pertinent citationat the head of a string citation. The depth of treatment process mayalso identify the page number of the legal case for all availablepagination on which the citation appears so that a depth record iswritten as many times as page breaks occur in the legal case.

The information about each citation in a legal case, such as the totalnumber of times that the citation appears in the legal case document,the types of each of these citations, and the page number for eachcitation occurrence is output in a file 148 which is stored in thedatabase 33. This information, in addition to any verified quotationsassociated with any of the occurrences of the citation, may be used togenerate both the “citations to the case” section described above andthe depth of treatment symbols. The technique for generating the depthof treatment symbols will be described in more detail below.

The negative treatment process 116 may include an automatic processingstep 150 and a manual verification step 152 which generate a list of thenegative history (i.e., other written opinions from other legal casewhich disagree with or overrule the current legal case) for the legalcase. During the automatic processing step 150, the file containing thelegal text with the marked up citations and quotations is scanned inorder to identify stems of certain words, such as “overrule”, “recede”,“disapprove”, or “distinguish”, which may indicate negative treatment.As an illustration, the process to identify the root of the word“overrule” in the text of the legal case is described. When an instanceof the root “overrule” is identified, a set of heuristic rules, asdescribed below, are applied to make a determination about whether thesentence containing the identified root is actually an overruling, asdescribed below with reference to FIG. 8. Then, during the manualverification process 152, a human operator of the system verifies theresults of the automatic process and the actual verified overrulings areadded to the case control database 124. The human operator may alsoidentify other negative history about the legal case which cannot beeasily identified automatically, as described below. The negativetreatment process aids a human operator in rapidly identifyingoverrulings. These overrulings are negative history which affect theauthority of the reasoning of the legal case.

The loci identification process 130 uses the file containing the legalcase text with marked up citations and quotations and a file 144containing the verified quotations, identifies any marked up citations,and applies a set of heuristic rules, as described below, to identifyand select a portion of text from around each citation which mayindicate the text supported by the citation. If a citation appearsmultiple times in a legal case, the surrounding text for each of theoccurrences of the citation is combined. In addition, if the quoteverification process, as described above, has verified any quotationassociated with that citation, the text of that verified quotation isalso combined with the other text surrounding the citation. All of theidentified text that surrounds each citation may then be used todetermine one or more headnotes or subject matter headings which may beapplicable to the citation. The subject matter heading classifies thecitation based on a predetermined number of subject matter areas, suchas Intellectual Property or Patents. A process 154 (Headqf) reads all ofthe text identified adjacent to a given citation and generates a naturallanguage search query to search an existing database for matches to theidentified text, as described below. The natural language query processis generally described in U.S. Pat. Nos. 5,265,065 and 5,418,948, whichare assigned to the same assignee as the present application and areincorporated herein by reference. The Headqf process 154 generates afile 156 containing the natural language queries. Using the naturallanguage queries, a subject matter assignment process step 158 runs thenatural language queries against a headnotes database to identifysubject matter headings, such as headnotes, which possibly match thetext surrounding the citation. For each matched subject matter heading,the query also generates a belief score value indicating how close thesubject matter heading match was to the text. A predetermined number ofthe most closely relevant subject matter headings and their beliefscores are provided to a thresholding process step 160.

The thresholding step uses the subject matter headings identified andperforms various calculations which take into account the rank of thesubject matter headings, the belief score of the subject matter headingsand the number of citations which reference that subject matter heading.After the calculations are performed, a predetermined number of topheadnote hits and a flag for each headnote indicating if the headnotepassed the thresholding are stored in the database 33 with a link to thecitation. These subject matter headings permit citations in the legalcase to be classified by and searched for using these subject matterheadings, as described above with reference to FIG. 2D. Now, the quoteidentification process will be described in more detail.

FIGS. 5 and 6 are diagram illustrating more details about the quoteidentification process 108 in accordance with the invention. The quoteidentification process 108 may include a lexical scanner process 170, aparagraph buffer 172 and a main loop process 174 to receive the text ofthe legal case and automatically generate a file containing eachquotation identified and a possible source for each quotation. Thelexical scanner 170 splits documents into logical fragments, known astokens, and these tokens are then used by the main loop process 174 toidentify quotations. The tokens which are identified by the lexicalscanner may include capitalized words, punctuation marks that might enda sentence, white space such as one or more spaces, case names, footnotereferences, start of quote markers and end of quote markers. The lexicalscanner process used may be based on any of a number of commerciallyavailable software applications, such as, for example, an applicationknown as FLEX, available from Sun Microsystems Inc, Mountain View,Calif. The lexical scanner accepts grammar specifying patterns andidentifies an action when a specific pattern is located. In particular,the lexical scanner, in accordance, with the invention may divide alegal case into the certain types of paragraphs based on a predeterminedset of criteria, such as a set of rules: 1) a paragraph which mightcontain a quotation; 2) paragraphs which are indented block quotations;3) paragraphs which contain important information about the document,such as the star of the document, the document's serial number or theend of the document; and 4) paragraphs which are of no interest to thequotation identification process, such as headnotes, headings and thelike. A variety of different criteria and rules may be used to identifythese paragraphs.

An example of a set of rules which may be used by the invention will nowbe described. The set may include a rule that identifies paragraphswhich do not contain any quotations and stores them in the paragraphbuffers where they are overwritten by the next paragraph, and a rule forparagraphs with possible quotations in which the lexical scanner returnsa tag to the main loop indicating that the paragraph is either a normaltext paragraph, an indented block quotation paragraph, or that the textof the quotation appears in a footnote. Once the type of the paragraphis determined, the lexical scanner processes the text within theparagraph in the same manner to identify any tokens in each paragraph.

Within each paragraph, the lexical scanner may identify the followingtokens: a capitalized word, a non-capitalized word, a numeric characterstring, an abbreviation, a proper name (i.e., “Mr. Smith”), a casecitation, a section reference (i.e., “Section 150”), a case name (i.e.,Roe v. Wade), an embedded reference, any end of the sentencepunctuation, any other punctuation characters, a colon, semicolon orcomma followed by a space, single or multiple white space characters, astart of a quotation, an end of a quotation, the number of a footnote,open and close parentheses, open and close brackets, open and closecurly braces, a mark-up for a citation, and a mark-up for an embeddedreference. More details about the operation and modification of the FLEXsoftware application is available from the Sun Microsystems Inc.Reference Manual, Programmer's Overview Utilities and Libraries, Chapter9, pp, 203-226, which is incorporated herein by reference.

The paragraph buffers 172 are where the tokens about the paragraph mostrecently scanned by the lexical scanner are stored before beingprocessed by the main loop 174 and then possibly written out into anoutput file if a quotation is identified in the paragraph. The main loop174 may decide what action to take for each token returned by thelexical scanner, manage the paragraph buffers, and decide when todiscard data for a previous paragraph from the paragraph buffer, linkseveral physical paragraphs together into a virtual paragraph forquotations which run over several physical paragraphs, determine wherethe breaks between sentences occur within a paragraph, and decide whento process a virtual paragraph by a set of heuristic rules, as describedbelow.

FIG. 6 is a flowchart of the quotation identification process 108 inaccordance with the invention. In step 180, the legal case text isscanned paragraph by paragraph and for each paragraph, the sentences andtokens in the paragraph are identified. In the step 182, a set ofheuristic rules is applied to each token in a paragraph to determine ifa quotation had been identified. One of the most important functions ofthe lexical scanner and the quotation identification process is toidentify the beginning and end of a quotation. This is difficult sinceeach writer may use a slightly different format for the beginning andending of a quotation. Therefore, several rules are needed to identifythe beginning and ending of a quotation. An example of a set ofheuristic rules that may be applied to accomplish such identificationwill now be described. These rules may use the lexical scanner toidentify a conventional start quotation punctuation symbol, such as“or”, to identify a conventional end of quotation delimiter, such as“or”, or to identify a start/end of quotation symbol in a longer stringof characters. For example, a rule may attempt to identify strings inwhich the conventional end of quotation symbol is embedded within asentence. For each of these rules, the characters surrounding the tokenmay be checked to ensure that the token is in fact a star of end of thequotation.

Once the rules have been applied to each token in a paragraph, thequotation identification process determines if another paragraph existsin step 184 and loop to step 180 to process a new paragraph. Once all ofthe paragraphs have been analyzed, in step 186, the process output thedata record containing the identified quotations and the possible sourceof those quotations. Now, the quotation verification process will bedescribed.

FIG. 7 is a flowchart illustrating the method 112 for verifying aquotation in accordance with the invention. At step 200, the quoteverification process reads in the text strings identified as quotationsby the quote identification process 108 and identifies separators, whenpresent, from a predetermined set of separators in the text strings. Theseparators may include ellipses, bracketed expressions, and stopphrases. The stop phrases include a variety of legal phrases and otherswhich do not help identify the source of a quotation, for example,“citation(s) omitted”, “sic”, “emphasis provided” and the like. Whenpresent, the separators are used to parse the text string into segmentsin which each segment includes the works that occur between a pair ofseparators. In step 202, the text string is parsed to determine itslength since the minimum verifiable quote length may be, for example,six non-stop words, where stop words are non-content bearing words suchas articles and prepositions. The text string is also parsed to collapseany words which contain apostrophes or other punctuation marks (e.g.,“T]hen”). The parsed quotation text string falls into one of twodistinct categories: (1) a text string with a single segment, or (2) atext string with multiple segments. Thus, in step 204, the systemdetermines if the text string has a single segment. If the text stringhas a single segment, then in step 205, the collection normalizedinverse document frequency (IDF) for each term (word) in the singlesegment of the text string is determined. A document frequency valueindicates the frequency of a particular term in a typical documentcollection, while IDF is equal to the reciprocal of document frequency(i.e., 1/doc freq), or in other words, the rarity of a term in adocument collection. In a preferred embodiment, the collectionnormalized inverse document frequency (IDF) may be calculated, if thenumber of occurrences of a word is greater than zero, as:

${idf\_ score} = \frac{\log\left( \frac{Collection\_ Docs}{Doc\_ Occurences} \right)}{\log({Collection\_ Docs})}$where Doc_Occurrences is the number of documents in which the given termis present and Collection_Docs is the total number of documents in thecollection. The IDF is used for purposes of determining good terms formatching, since a rare word is more likely to be distinct and provide agood indication that the quotation is from the candidate source.

Once the IDF has been calculated for each term, a selected number of theterms (i.e., six) with the highest IDF values below a selected thresholdmay be ranked by IDF value (step 206) and placed into a “template”(i.e., storage array) (step 207) which indicates the position of eachterm in the text string. Any terms with an unusually high IDF value(e.g., greater than 0.80) are not used, since such infrequentlyoccurring terms are often misspelled words. If there are several termswith the same IDF value, then the alphanumeric ordering of the terms maybe used as a secondary key for ranking the terms for the template.Should there still exist equivalent terms (e.g., terms with the same IDFvalues and alphanumeric spellings) then the position of the terms in thetext string may be used as a third key for ranking the terms in thetemplate. The template may then be compared to the quotation from thecandidate source document to determine if an exact match, based on thepositions of the high IDF terms, occurs in step 208. If an exact matchoccurs, then in step 210, the verified quotation is output and fed intothe database as described above. In the event that an exact match doesnot occur in step 212, a certification match failure message isgenerated and the quotation is not stored in the database.

In step 204, if the text string has multiple segments (i.e., it containsone or more separator terms in the text string, such as “The roof fellin . . . crashing down”), the process goes to step 214 in which the IDFfor each term within each required segment is determine. Then, aselected number of terms (e.g., four) within each segment, with thehighest IDF values below the threshold, are ranked by IDF (step 215) andplaced into a template (step 216) in order to determine the position ofthe terms in the segment for matching purposes (step 208). For a textstring with more than four segments, the first two and last two segmentsmay be used to match against the candidate source document (step217-218). In this manner, the quotations identified by the automaticquote identification process are automatically verified and any verifiedquotations are identified by a quotation symbol, as described above.Now, the negative treatment process in accordance with the inventionwill be described.

FIG. 8 is a diagram illustrating a method 220 for determining thenegative treatment of a legal case in accordance with the invention. Thefile 110 containing the text of the legal case with the marked upquotations and citations is input into the automatic negative treatmentprocess 150. The automatic negative treatment process may 1) identifyoccurrences of the word stem “overrul” in the legal case; 2) determinethe proximity of the stem to a citation; and 3) exclude any bad legalcases. Prior to identifying the stem “overrul”, the case controldatabase 124 may be checked and the automatic processing stopped if anyhistory already exists for the legal case. To identify the occurrencesof the stem “overrul”, the text of the legal case is are scanned and theverb tense of any occurrences of the stem is determined. The verb tenseof the stem indicates whether the overruling refers to the current caseoverruling a previous case or some other type of overruling. A set ofheuristic rules may look for a particular verb tense and then take anaction based on the verb tense.

An example of the set of the rules used will now be described, but theinvention is not limited to any particular set of rules. For example,one rule may locate “overrule” or overrules” in a sentence and thenscans backwards for up to four words. If “not” or never” is located,then the sentence is discarded since it does not refer to an actualoverruling. If “we” is found, then the sentence is added to the list ofpossible overruling which are reviewed by a human being. If none of thephrases is located during the backwards scan, the sentence is also addedto the list.

Another rule may locate “overrule” and then scans backwards for up tofive words to attempt to locate non-case words which would indicate thatsomething other than the legal case is being overruled so that thesentence is not added to the list. A few examples of these non-casewords include “request”, “motion”, “objection”, “claim”, and “verdict”.If the rule locates “point” or “points”, then the sentence may bescanned forward to the end of the sentence and if “case”, “cases” or“supra” is located, then the status of the sentence is unknown and it ispassed on to the human reviewer.

Another rule may locate “overrule” and scan backwards or forwards, andreject or accepts possible overrulings based on the other words withinclose proximity to the word “overrule” since these additional words willprovide the context in which the word “overrule” is being used. Forexample, once “overrule” is located, four words before the word may bescanned and the following actions are taken when the following words arelocated: 1) if “we” is located, and the word prior to “we” is “that”,the “we” is ignored (discussion about overruling only), but if no word“that” is located, then the sentence is a possible overruling; 2) if theverb is modified by a word that indicates uncertainty, such as “rather”,“might”, etc. . . . the sentence is rejected since the court may be onlyindicating it might overrule the case; 3) if any word indicates adiscussion of an overruling, then the sentence is rejected; 4) if a wordindicates that another person did the overruling, then the sentence isrejected; and 5) if “will” or “should” are located, the process looksback five words for a positive word in order to accept the sentence.There may also be a similar set of rules for the verb “overrules”, theinfinitive form of the verb and the passive voice of the verb.

Another set of rules may look for various words which indicate adiscussion of whether to overrule, whether a court has the authority tooverrule or a past overruling since these sentences are rejected as notcontaining an actual overruling. Another set of rules may rejectsentences which indicate that someone else is doing the overruling(i.e., another court in the past). Still another rules may look for“overruling” and then determine if the sentence is rejected or acceptedbased on the sentences surrounding the word, as described above.

There are also other rules which look for particular features of asentence independent of the verb “overrule”. For example, if the phrase“COURT:” is located at the beginning of a sentence, which indicates adirect quotation from the judge, the sentence may be accepted. If theword “Congress” is located at the beginning of a sentence, which mayindicate that a Congressional statute is being overruled or thatCongress itself is overruling a case, the sentence may be rejected. Ifthe word “circulated” is found in a sentence near the word “overrule”,the sentence may be accepted to catch unusual language, such as “becausethe decision overrules an opinion of this court, it was circulated toall active judges . . . ” which could not be automatically identified insome other manner. Another rule may look for “overrule” within a quotedstring and reject the sentence since it is usually an overruling byanother court of a case which is being quoted by the current court.

In addition to the word stem “overrul”, other synonyms may be searchedfor and identified. For example, the rules may also detect the word stem“abrogat” for California cases which use the term “abrogated” and thephrase “receded from” for Florida cases since these terms are used toindicate an overruling in each respective state. These verb tense rulesmay be applied in any order and the invention is not limited to anyparticular set of rules or any particular order of execution of therules.

The output of the set of verb tense rules from the automatic negativetreatment process is a list of possible overrulings. Then, a proximityrule is applied to each possible overruling to determine if theoverruling applies to a particular legal case. For example, theproximity rule may eliminate a possible overruling if the sentencecontaining the stem does not contain a citation, if the previous or nextsentence does not contain a citation or the sentence with the stem“overrul” does not contain a word or phrase used to refer to a case suchas “case”, “opinion”, “holding”, “precedent”, their plurals or “progeny”or “v.”, “ex rel”, “ex parte” or “supra”. Any sentences which containsthe stem “overrul” and satisfies the proximity rules are added to asuggested list 222 of overruling in the legal case. These suggestedoverrulings are then reviewed and checked during the manual reviewprocess step 152 by a human being. The human being, during the manualreview process, also determines the case which is overruled and thatdata is entered into the case control database 124 which tracks legalcases within the legal cases database.

In accordance with another aspect of this negative treatment process,the automatic process may also identify relationships other thanoverruled, such as “disting” for “distinguished” or “apposite” in alegal case, by extending the method to the language that characterizesthose other relationships. In summary, the negative treatment processaids the human reviewer in determining possible overruling in the legalcases by automatically determining possible locations of overruling sothat the amount of text that has to be actually reviewed by the humanbeing is significantly reduced. Thus, the negative treatment processincreases the speed with which overruling in a legal case may beidentified and added into the negative history of the legal case. Now,the depth treatment process will be described in more detail.

FIG. 9 is a flow chart of the depth treatment process 114 in accordancewith the invention in which a depth treatment symbol is assigned to eachcitation within a legal case so that a person using the system mayquickly determine the amount of text devoted to discussing a particularcitation. This information may be utilized as one indication of therelevance of the citation since a court will devote more text anddiscussion to a highly relevant citation.

At step 230, the file with the text of the legal case and the marked upcitations and quotations, as described above, is received by the depthtreatment process. At step 232, the depth treatment process identifies acitation in the legal case, and then in step 234, the type of citationis determined. Each citation in the legal case may be 1) a citation atthe head of a string citation; 2) a citation without other accompanyingcitations; 3) a citation within the interior of a string citation; or 4)a pro form a history citation (i.e., a citation that, in the context ofthe document, are cited solely as a ancillary historical references forone of the cases cited in its own right). Each of these types ofcitations has a different amount of significance. For example, a lonecitation or a citation at the head of a string citation tends to be moresignificant than a citation in the middle of the string.

The depth treatment process next determines if there are any additionalcitations in the legal case in step 236 and loops back to step 232 toprocess the next citation in the legal case. Once all of the citationsin the legal case have been identified and sorted into one of the typesdescribed above, they are fed into the grouper process 126 as shown inFIG. 3. After the grouper process, in step 238, the depth treatmentprocess determines, for each different citation, the total number ofeach type of citation in the legal case. For example for a citation toPleasant v. Celli, there may be a total of five cites in the legal caseof which three are at the head of a string citation and two are withinthe interior of a string citation. This information about each citationin the legal case and any data about a verified quotation which isassociated with a particular citation are used in step 240 to determinethe depth symbol which will be assigned to the particular citation. Oncethe depth symbols have been assigned for each citation, the depthtreatment process has been completed.

One example of a technique for assigning a depth symbol to a particularcitation will now be described, but the invention is not limited to anyparticular technique for assigning the depth symbols. In addition, theinvention is not limited to any particular type of depth symbol. In thisexample, a citation in the legal case with one to three occurrences ofany type of citation (i.e., the citation standing along, the citation isthe head of the string citation or the citation is in the middle of astring citation) in the legal case is assigned two stars (e.g., **), acitation in the legal case with four to eight occurrences of any type ofcitation is assigned three stars (e.g., ***), and a citation with nineor more occurrences of any type of citation is assigned four stars(e.g., ****). To further refine these assignments, a citation with threeoccurrences of any type of citation and a verified quotation associatedwith the citation is assigned three stars (e.g., ***) while if acitation has only internal string citation types, one star is deductedfrom that citation. Thus, the depth symbol for a particular citation inthe legal case is automatically assigned by the system in accordancewith the invention. The depth symbols help a user of the system morequickly determine which citations are probably more relevant. Now, thesubject matter text assignment process in accordance with the inventionwill be described.

FIG. 10 is a flowchart illustrating a method 250 in accordance with theinvention for assigning a piece of text from the cited case to thecitation in the legal case. In the example described below, the text ofa headnote in the cited case is assigned to the citation, but the textassignment process in accordance with the invention may be utilized witha plurality of different pieces of text in the cited cases. In step 252,a citation locus (i.e., a region of text likely to correspond to thetext supported by the citation) for each citation is assigned accordingto the a set of rules which are now described.

To identify the citation locus, several text-parsing rules may be used,some of which are stronger than others, but which collectively would behighly likely to identify the text. To allow for varying effectivenessof the different rules, the extracted text may be divided into threegroups, “high”, “medium” and “low”, according to the likelihood that theextracted text was part of the correct citation locus. These rules mayinclude:

Category Text High 1. any non-citation material contained in thesentence that includes the base citation. 2. all of the firstnon-citation sentence preceding the base citation within the sameparagraph. 3. if there is no type 2 sentence, then all of the firstnon-citation sentence following the citation within the same paragraph.4. all text that can be identified as a quotation form the cited case.Medium 5. all sentences occurring between the citation next preceding(but not contiguous to) the base citation and a type 2 sentence. 6. allsentences occurring between the citation next following (but notcontiguous to) the base citation and a type 3 sentence. 7. if there isnot type 2 or type 3 sentences, and the paragraph containing the basecitation ends with a colon or comma, the whole of the paragraph nextfollowing the paragraph containing the base citation 8. if there is nottype 2 or type 3 sentences and no type 6 paragraph, the whole of theparagraph next preceding the paragraph containing the base citation 9.if any of the text areas identified by any rule includes a headnotereference marker, include the headnote and its keyline Low 10. the wholeof the paragraph containing the base citation General 11. if thecitation occurs in a footnote, it is treated as if it occurred at boththe footnote location and the location of the footnote marker Not Posted12. citations occurring only in the subsequent history of anothercitation

Then, in step 254, the terms in the citation loci are weighted accordingto the rule that was used to identify them, with a high, medium or lowmatching corresponding to weights of 2.0, 1.0 and 0.5, respectively.Different types of documents, such as legal cases or law reviewarticles, may require a different set of rules to determine the weights.Once the pieces of text have been identified and assigned a beliefvalue, in step 256, the identified pieces of text are matched againstpieces of text which may be within the cited document. In one example,the pieces of text within the cited document may be headnotes, but theinvention is not limited to any particular type of text which theidentified pieces of text are matched against. The matching may be doneusing natural language query as described in previously referenced U.S.Pat. Nos. 5,265,065 and 5,418,948 which are owned by the assignee ofthis application and are incorporated herein by reference. The resultsof the search is a list of possible pieces of text from the cited case,such as a headnote, which may be assigned to the citation in the legalcase and a belief score for each possible piece of text.

Next, in step 258, the one or more pieces of text that are going to beassigned to the citation are selected though a thresholding process. Thethresholding process ranks the pieces of text for each citation based onthe belief score. The piece of text may be posted to the databasewhenever the following quantity equals or exceeds 0.5:

$\frac{1}{\,_{1 + e}{- \begin{pmatrix}{\beta_{0} + {\beta_{1}\sqrt{{belief} - 0.4}} +} \\{{\beta_{2}{{In}({freq})}} + {\beta_{3}{{In}\left( {{belief} - {{lag}\; 2} + 0.0001} \right.}}}\end{pmatrix}}}$The beta values for this equation are as follows:

Document Rank β₀ β₁ β₂ β₃ non-ALR 1 4.0451 3.1975 0.8477 .9033 non-ALR 20.5573 9.0220 1.0348 0.6743 non-ALR 3 −2.0421 11.2619 0.8949 0.2954 ALR1 −1.4256 50.4929 0.3488 0.0000 ALR 2 −2.8199 65.6148 0.6207 0.0000 ALR3 −2.3701 40.8479 1.2445 0.0000 ALR 4 −3.3474 60.8075 1.7349 0.0000 ALR5 −3.0805 55.6003 1.3188 0.0000where the columns marked “ALR” contain variables for ALR articles, asdescribed above, which have a higher belief score than the non-ALRdocuments. The columns labeled “non-ALR” contain variables for non-ALRdocuments.

In the equation, Freq is the total citation frequency for the citationpair, and lag2 is the belief score of the second following candidatewhen the candidates are sorted by belief score in descending order (or0.4 if there is no such candidate). Once the thresholding has beencompleted and the one or more pieces of text has been assigned to eachcitation in the legal case, one or more pieces of text are stored in thedatabase in step 260 as described above so that it may be retrieved fora user when requested.

In summary, the subject matter assignment process automaticallygenerates one or more pieces of text for a citation in the legal casebased on pieces of text in the cited case such as a headnote. Theprocess first automatically identifies supporting text in the legal caseand assigns a belief value to the supporting text, matches all of thepiece of text against pieces of text in the cited cases, and thenautomatically assigns a piece of text, such as a headnote, from thecited case to the particular citation. These subject matter assignmentspermit a citation to the legal case to be sorted or selected by thesubject matters which helps during the collocation process.

Thus, the machine implemented system in accordance with the inventionautomatically processes a document, such as a legal case, and generatesinformation about the document which may provide the user of the systemwith useful information about the contents of the document. In aconventional system, on the other hand most of this information aboutthe document would be generated by a human being reading the documentand making notes about the document which is a slow, expensive,error-prone process. For a legal case, the system may automaticallygenerate information about the negative history of the legal case, aboutthe depth treatment of a citation by the legal case, about the quotationin the legal case which are verified as originating from a particularsource, and about one or more headnote which are assigned to aparticular citation in the legal case. Thus, the operator of the systemmay rapidly generate this information about the legal case and a user ofthe system may quickly locate this information since it is all readilyaccessible from a graphical user interface.

While the foregoing has been with reference to a particular embodimentof the invention, it will be appreciated by those skilled in the artthat changes in this embodiment may be made without departing from theprinciples and spirit of the invention, the scope of which is defined bythe appended claims.

What is claimed is:
 1. A computer-implemented method comprising:identifying by a computer processor a case law citation; searchingelectronically stored legal cases to identify instances where legalcases contain citation to the identified case law citation; determiningby a computer processor if one or more of the identified citationinstances provides a negative legal depth-of-treatment regarding theidentified case law citation; and generating a legal depth-of-treatmentsymbol to be displayed on a user computer indicative that the identifiedcase law citation has negative legal depth-of-treatment.
 2. A computerimplemented method as recited in claim 1 wherein the legaldepth-of-treatment symbol is a colored symbol.
 3. A computer implementedmethod as recited in claim 2 wherein the colored symbol is a flagsymbol.
 4. A computer implemented method as recited in claim 1 whereinthe legal depth-of-treatment symbol includes identification of a legalcase providing negative legal depth-of-treatment for the identified caselaw citation.
 5. A computer implemented method as recited in claim 4wherein user selection of a legal depth-of-treatment symbol on said usercomputer identifies at least a portion of the identified legal caseassociated with the user selected legal depth-of-treatment symbol.
 6. Anapparatus comprising: a memory; a processor disposed in communicationwith said memory, and configured to issue a plurality of instructionsstored in the memory, wherein the instructions cause the processor to:identify occurrences of a piece of text having a predetermined format anelectronically stored textual document; determine a legaldepth-of-treatment for at least one piece of identified formatted textin the textual document to determine a significance of the at least onepiece of formatted text based on predetermined criteria; and determine alegal depth of symbol indicative of the determined legaldepth-of-treatment for the at least one piece of formatted text in theelectronically stored textual document.
 7. An apparatus as recited inclaim 6 wherein the determined legal depth-of-treatment for the at leastone piece of identified formatted text is negative legaldepth-of-treatment relative to case law associated with the at least onepiece of identified formatted text.
 8. An apparatus as recited in claim6 wherein the instructions further cause the processor to associate anabstract with each piece of formatted text in the textual document. 9.An apparatus as recited in claim 8 wherein the instructions furthercause the processor to generate a data record containing each identifiedpiece of formatted text from the textual document, thedepth-of-treatment value and the abstract associated with each piece offormatted text in the textual document.
 10. An apparatus as recited inclaim 6 wherein the predetermined criteria for determining thesignificance of the piece of formatted text includes a number ofoccurrences the piece of formatted text appeared in the textualdocument.
 11. An apparatus as recited in claim 6 wherein thepredetermined criteria for determining the significance of the piece offormatted text includes a citation type associated with the piece offormatted text.
 12. An apparatus as recited in claim 6 wherein thepredetermined criteria for determining the significance of the piece offormatted text includes a page number for a legal case on which thepiece of formatted text appears.
 13. An apparatus as recited in claim 6wherein the legal depth-of-treatment symbol is a colored symbol.
 14. Acomputer implemented method as recited in claim 13 wherein the coloredsymbol is a flag symbol.
 15. An apparatus comprising: a memory; aprocessor disposed in communication with said memory, and configured toissue a plurality of instructions stored in the memory, wherein theinstructions cause the processor to: identify by a computer processor acase law citation in a textual document; search electronically storedlegal cases to identify instances where legal cases contain citation tothe identified case law citation; determine if one or more of theidentified citation instances provides a negative legaldepth-of-treatment regarding the identified case law citation; andgenerate a legal depth-of-treatment symbol to be displayed on a usercomputer indicative that the identified case law citation has negativelegal depth-of-treatment.
 16. An apparatus as recited in claim 15wherein the legal depth-of-treatment symbol is a colored symbol.
 17. Anapparatus as recited in claim 16 wherein the colored symbol is a flagsymbol.
 18. An apparatus as recited in claim 15 wherein the legaldepth-of-treatment symbol includes identification of a legal caseproviding negative legal depth-of-treatment for the identified case lawcitation.
 19. An apparatus as recited in claim 18 wherein user selectionof a legal depth-of-treatment symbol on said user computer identifies atleast a portion of the identified legal case associated with the userselected legal depth-of-treatment symbol.